Safety Standards for Underground Coal Mine Ventilation - Belt Entry Used as an Intake Air Course to Ventilate Working Sections and Areas Where Mechanized Mining Equipment is Being Installed or Removed
1219-0138
October 2016
Supporting Statement for
Paperwork Reduction Act Submissions
OMB Control Number: 1219 - 0138
Title: Safety Standards for Underground Coal Mine Ventilation - Belt Entry Used as an Intake Air Course to Ventilate Working Sections and Areas Where Mechanized Mining Equipment is Being Installed or Removed
Form Number(s): None
Authority: 30 CFR 75.350, 75.351, 75.352, 75.371
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses or employ statistical methods” is checked "Yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.
Specific Instructions
A. JUSTIFICATION
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and of each regulation mandating or authorizing the collection of information.
Section 103(h) of the Federal Mine Safety and Health Act of 1977 (Mine Act), 30 U.S.C. 813(h), authorizes the Mine Safety and Health Administration (MSHA) to collect information necessary to carry out its duty in protecting the safety and health of miners. Further, Section 101(a) of the Mine Act, 30 U.S.C. 811 authorizes the Secretary to develop, promulgate, and revise as may be appropriate, improved mandatory health or safety standards for the protection of life and prevention of injuries in coal and metal and nonmetal mines.
The use of air from a belt air course to ventilate a working section, or an area where mechanized mining equipment is being installed or removed, is permitted only when evaluated and approved by the district manager in the mine ventilation plan. MSHA safety standards for ventilation of underground coal mines establish additional protective measures that mine operators must follow if they want to use belt air for ventilation purposes. Sections 75.350, 75.351, 75.352, 75.371 contain paperwork requirements to ensure that mine operators are in compliance with the ventilation standards.
Section 75.350(b) requires that the mine operator must include in a ventilation plan a justification that the use of air from a belt entry would afford at least the same measure of protection as where belt haulage entries are not used. The plan also must include information regarding point feeds and regulators and designated areas for dust and air velocity measurements.
Section 75.351(b)(3) and (4) require a mine operator to post a map or schematic, at a designated surface location, which shows the locations and type of Atmospheric Monitoring System (AMS) sensors at each location and the intended air flow direction at these locations. This map or schematic must be updated within 24 hours of any change in this information. Contact information for AMS and other appropriate personnel also must be posted at this location.
Section 75.351(j) requires approval of the CO ambient levels, and the means to determine those levels, in the mine ventilation plan.
Section 75.351(m) permits a mine to incorporate time delays into the AMS, or to use other methods for reducing non-fire alerts and alarm levels, provided they are specified and approved in the mine ventilation plan. Permission for such time delays, or other methods of reducing non-fire alerts and alarms, would be granted based on associated documentation that justifies these changes.
Sections 75.351(n)(2) and 75.351(n)(3) require that alarms for AMS be tested every seven days and CO, smoke, or methane sensors be calibrated, every 31 days, respectively.
Section 75.351(o)(1)(i) requires that a record be made if the AMS emits an alert or alarm signal. The record would consist of the date, time, location, and type of sensor, and the reason for its activation.
Section 75.351(o)(1)(ii) requires that, if an AMS malfunctions, a record be made of the date, the extent and cause of the malfunction, and the corrective action taken to return the system to proper operating condition.
Section 75.351(o)(1)(iii) requires that the persons doing the weekly test of alert and alarm signals, the monthly calibration, or maintenance of the system make a record of these tests, calibrations, or maintenance.
Section 75.351(o)(3) requires that all records concerning the AMS be kept in a book or electronically in a computer system that is secure and not susceptible to alteration.
Section 75.351(p) requires the mine operator to keep these records for at least one year at a surface location and to make them available for inspection by authorized representatives of the Secretary and representatives of miners.
Section 75.351(q)(3) requires that a record of annual AMS operator training be kept. The record will include the content of training, the person conducting the training, and the date the training is conducted. The record needs to be maintained at the mine site by the mine operator for at least one year.
Sections 75.352(a), (b) and (c) require the designated AMS operator or other appropriate personnel to notify, investigate, or evacuate when malfunction, alert, or alarm signals are received.
Section 75.371(hh) requires reporting within the mine ventilation plan of the "ambient level in parts per million of carbon monoxide, and the method for determining the ambient level, in all areas where carbon monoxide sensors are installed." This provision is impacted by section 75.351(j).
Section 75.371(kk) requires the locations where air quantities are measured as set forth in section 75.350(b)(6) be included in the mine ventilation plan.
Section 75.371(ll) requires the locations and use of point feed regulators, in accordance with Sections 75.350(c) and (d)(5),to be in the mine ventilation plan.
Section 75.371(mm) requires the location of any diesel-discriminating sensor and additional carbon monoxide or smoke sensors installed in the belt air course to be included in the mine ventilation plan.
Sections 75.371(nn), (oo), and (pp) require modification of the mine ventilation plan to show the length of the time delay or any other method used for reducing the number of non-fire related alert and alarm signals from CO sensors, the lower alert and alarm setting for CO sensors, and the alternate instrument and the alert and alarm levels associated with the instrument, respectively.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
The respondents are mine operators that elect to use belt air to ventilate working sections and areas where mechanized equipment is being installed or removed. The records will be used by coal mine supervisors, miners, State mine inspectors, and Federal mine inspectors. The records show that the required examinations and tests were conducted. These records give insight into the hazardous conditions that have been or may be encountered. The records of inspections greatly help to make decisions that will ultimately affect the safety and health of miners working in belt air mines.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
Mine operators may retain the records either in a secure book that is not susceptible to alteration, or electronically in a computer system that is secure and not susceptible to alteration. MSHA encourages operators who store records electronically to provide a mechanism that will allow the continued storage and retrieval of records. MSHA currently accepts automatic printing of alert and alarm signals and automatic storage of some data. No other improved information technology has been identified that would reduce the burden.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in 2 above.
MSHA knows of no other Federal or State reporting requirements that duplicate the reporting requirements contained in this section.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not have a significant impact on a substantial number of small entities.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Reduction of these requirements could result in increased hazards to miners. If the information collections are not conducted, the consequences could be severe. A reduction in the frequency of examinations and tests associated with these information collections could allow unsafe conditions to develop and jeopardize the safety of the miners.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
requiring respondents to report information to the agency more often than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records, other than health, medical, government contract, rant-in-aid, or tax records for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
This collection of information is consistent with the guidelines in 5 CFR 1320.5.
8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.
MSHA published a 60-day Federal Register notice on June 30th, 2016 (81 FR 42735). MSHA received no comments.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
MSHA will not provide payments or gifts to respondents identified by this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
There is no assurance of confidentiality provided to respondents. The mine operator maintains records that are reviewed by MSHA inspectors during routine inspections.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There are no questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.
Seventeen mines use “Belt Air” and/or “Point Feeding.” These mines are the number of respondents for this collection. For purposes of calculating burden, all times have been rounded to the nearest hour.
Section 75.351(j) requires approval of the Carbon monoxide (CO) ambient levels, and the means to determine those levels, in the mine ventilation plan. Only mines that have detected ambient levels of CO are required to establish an ambient level. Since MSHA expects only 50% of mines to establish non-zero CO ambient levels, the number of responses is only 50% of the 17 mines using belt air. MSHA estimates that to perform the tasks of the requirement will take an underground coal mine supervisor, earning $103.26 per hour 1, 8 hours per affected belt-air mine.
8 hours x 9 responses = 72 hours
72 hours x $103.26 per hr. = $7,435
Section 75.371(hh) requires reporting within the mine ventilation plan of the "ambient level in parts per million of carbon monoxide, and the method for determining the ambient level, in all areas where carbon monoxide sensors are installed." This provision is impacted by section 75.351(j). Since MSHA estimates only 50% of mines have established non-zero CO ambient levels, the number of responses is only 50% of the 17 mines using belt air. MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 15 minutes per affected belt-air mine.
15 minutes x 9 responses = 2 hours
Section 75.351(m) permits a mine to incorporate time delays into the AMS, or to use other methods for reducing non-fire alerts and alarm levels, provided they are specified and approved in the mine ventilation plan. Permission for such time delays, or other methods of reducing non-fire alerts and alarms, would be granted based on associated documentation that justifies these changes. MSHA estimates that only 40% of belt air mines use time delays. Hence, the number of responses is 7 of the 17 mines using belt air. MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 8 hours per affected belt-air mine.
8 hours x 7 responses = 56 hours
56 hours x $103.26 per hr. = $5,783
Section 75.351(n)(2) requires weekly testing of the alarms for an AMS. This weekly testing is accompanied by a documentation requirement in Section 75.351(o)(1)(iii). MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 33 hours annually per affected belt-air mine.
33 hours x 17 responses = 561 hours
561 hours x $103.26 per hr. = $57,929
Section 75.351(n)(3)(i) requires monthly calibration of the CO sensors for an AMS. This monthly calibration is accompanied by a documentation requirement in Section 75.351(o)(1)(iii). MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 128 hours annually per affected belt-air mine.
128 hours x 17 responses = 2,176 hours
2,176 hours x $103.26 per hr. = $224,694
Section 75.351(o)(1)(i) requires a record of all alerts and alarms of an AMS. Section 75.351(o)(1)(ii) requires a record of all malfunctions of an AMS. MSHA estimates that to perform the tasks of the requirement will take an underground coal miner, earning $76.42 per hour 2, 8 hours annually per affected belt-air mine.
8 hours x 17 responses = 136 hours
136 hours x $76.42 per hr. = $10,393
Section 75.351(o)(1)(iii) requires a record of all testing, calibration, and malfunctions of an AMS. The recording of the name, date and signature of the person entering the record, required by section 75.351(o)(2), is included in this estimate. MSHA estimates these three recordkeeping requirements separately below.
MSHA estimates that to perform the tasks of the requirement will a miner, earning $76.42 per hour, 2 hours annually per affected belt-air mine.
2 hours x 17 responses = 34 hours
34 hours x $76.42 per hr. = $2,598
MSHA estimates to perform the tasks of the requirement will take a miner, earning $76.42 per hour, 6 hours annually per affected belt-air mine.
6 hours x 17 responses = 102 hours
102 hours x $76.42 per hr. = $7,795
MSHA estimates that to perform the tasks of the requirement will take a miner, earning $76.42 per hour, 2 hours annually per affected belt-air mine.
2 hours x 17 responses = 34 hours
34 hours x $76.42 per hr. = $2,598
Section 75.351(q)(3) requires that a record be kept of annual training of all AMS operators in the proper operation of the AMS and the names of designated AMS operators required by 75.351(b)(4) is part of this. MSHA estimates to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 15 minutes per affected belt-air mine.
15 minutes x 17 responses = 4 hours
4 hours x $103.26 per hr. = $413
Sections 75.352(a), (b), and (c) require procedures to be followed in response to all alerts, alarms, and malfunction signals of an AMS. These procedures are accompanied by a documentation requirement in Sections 75.351(o)(1)(i) and (ii). MSHA estimates that to perform the tasks of the requirement will take a miner, earning $76.42 per hour, 15 hours per affected belt‑air mine.
15 hours x 17 responses = 255 hours
255 hours x $76.42 per hr. = $19,487
Section 75.371(kk) requires reporting within the mine ventilation plan of the “locations where air quantities are measured as set forth in Section 75.350(b)(6).” The burden associated with section 75.351(b)(3) which requires posting of a map at the mine’s surface is included in this estimate. MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 10 minutes per affected belt-air mine.
10 minutes x 17 responses = 3 hours
3 hours x $103.26 per hr. = $310
Section 75.371(ll) requires reporting within the mine ventilation plan of the “locations and use of point-feed regulators, in accordance with Sections 75.350(c) and 75.350(d)(5).” MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 10 minutes per affected belt-air mine.
10 minutes x 17 responses = 3 hours
3 hours x $103.26 per hr. = $310
Section 75.371(nn) requires reporting within the mine ventilation plan of the “length of the time delay or any other method used to reduce the number of non-fire related alert and alarm signals from carbon monoxide sensors.” MSHA expects that only 40% of diesel mines would use time delays, and no non-diesel mines would use time delays. Hence, the number of responses is 7 of the 17 mines using belt air. MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 15 minutes per affected belt-air mine.
15 minutes x 7 responses = 2 hours
2 hours x $103.26 per hr. = $207
Section 75.371(oo) requires reporting within the mine ventilation plan of the “reduced alert and alarm settings for carbon monoxide sensors, in accordance with section 75.351(i)(2).” Since only 5 percent of mines are expected to reduce alert and alarm levels, the number of responses is only 1 of the 17 mines using belt air. MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 15 minutes per affected belt-air mine.
15 minutes x 1 response = 0 hours
0 hours x $103.26 per hr. = $0
Section 75.371(pp) requires reporting within the mine ventilation plan of the “alternate detector and the alert and alarm levels associated with the detector, in accordance with section 75.352(e)(7).” Since only 10% of mines are expected to use smoke detectors that require substitute hand-held detectors for emergency use, the number of responses is 2 of the 17 mines using belt air. MSHA estimates that to perform the tasks of the requirement will take a supervisor, earning $103.26 per hour, 15 minutes per affected belt-air mine.
15 minutes x 2 responses = 1 hour
1 hour x $103.26 per hr. = $103
Question 12 Totals
Total Burden Hours = 3,441
Total Burden Hour Costs = $340,262
Total Respondents = 17
Total Responses = 205
Total Question 12 Annual Burden Hours and Costs
Summarized by Provision
Section |
Responses |
Burden Hours |
Burden Hour Costs |
75.351(j) |
9 |
72 |
$7,435 |
75.351(j) & 75.371(hh) |
9 |
2 |
$207 |
75.351(m) |
7 |
56 |
$5,783 |
75.351(n)(2) |
17 |
561 |
$57,929 |
75.351(n)(3) |
17 |
2,176 |
$224,694 |
75.351(o)(1)(i) & (ii) |
17 |
136 |
$10,393 |
75.351(o)(1)(iii) weekly |
17 |
34 |
$2,598 |
75.351(o)(1)(iii) monthly |
17 |
102 |
$7,795 |
75.351(o)(1)(iii) maintenance |
17 |
34 |
$2,598 |
75.351(q)(3) |
17 |
4 |
$413 |
75.352(a), (b) & (c) |
17 |
255 |
$19,487 |
75.371(kk) |
17 |
3 |
$310 |
75.371(ll) |
17 |
3 |
$310 |
75.371(nn) |
7 |
2 |
$207 |
75.371(oo) |
1 |
0 |
$0 |
75.371(pp) |
2 |
1 |
$103 |
Total |
205 |
3,441 |
$340,262 |
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet.)
The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
Section 75.351(o)(3). Record security of tests, calibrations, and maintenance
Section 75.351(o)(3) requires safekeeping of records for one year of all alerts, alarms, malfunctions, maintenance, examination, testing, and calibration for an AMS in a secure book that is not susceptible to alteration. MSHA estimates $20 of materials cost per affected mine to purchase a secure book.
$20 cost per mine x 17 mines = $340
Section 75.351(n)(3)(i) requires monthly calibration of the CO sensors for an AMS. This monthly calibration is accompanied by a documentation requirement in section 75.351(o)(1)(iii). An AMS for a belt-air mine is assumed to have 40 sensors with a replacement cost of $80 per sensor. Sensors are replaced annually.
40 sensors per mine x 17 mines x $80 per sensor = $54,400
Total Question 13 Cost Burden = $54,740
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
There is no cost to the Federal Government.
Explain the reason for any program changes or adjustments reported on the burden worksheet.
Respondents: The number of respondents is reduced from 21 to 17.
Responses: The number of responses is reduced from 251 to 205.
Hours: There has been a decrease in burden hours from 4,245 to 3,441 due to a decrease in respondents.
Costs: The cost to respondents has increased from $40,664 to $54,740, mainly due to the increase price for an AMS sensor.
Burden Changes Summary Table
Section |
Burden Hours on OMB Inventory |
Adjustment: New Burden Hours (Rounded) |
Change |
75.351(j) |
88 |
72 |
-16 |
75.351(j), 75.371(hh) |
3 |
2 |
-1 |
75.351(m) |
64 |
56 |
-8 |
75.351(n)(2) |
693 |
561 |
-132 |
75.351(n)(3) |
2,688 |
2,176 |
-512 |
75.351(o)(1)(i) & (ii) |
168 |
136 |
-32 |
75.351(o)(1)(iii) weekly |
42 |
34 |
-8 |
75.351(o)(1)(iii) monthly |
126 |
102 |
-24 |
75.351(o)(1)(iii) maintenance |
42 |
34 |
-8 |
75.351(q) |
5 |
4 |
-1 |
75.352(a), (b) & (c) |
315 |
255 |
-60 |
75.371(kk) |
4 |
3 |
-1 |
75.371(ll) |
4 |
3 |
-1 |
75.371(nn) |
2 |
2 |
0 |
75.371(oo) |
0 |
0 |
0 |
75.371(pp) |
1 |
1 |
0 |
TOTAL |
4,245 |
3,441 |
-804 |
16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
MSHA does not intend to publish the results of this information collection.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
This collection does not seek approval to not display the expiration date for OMB approval.
18. Explain each exception to the topics of the certification statement "Certification for Paperwork Reduction Act Submissions."
MSHA does not request an exception to the certification of this information collection.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
There is no statistical methodology involved in this collection.
1 Hourly wage rate, including benefits, developed from tabulations in the U.S. Coal Mines Salaries, Wages, and Benefits – 2012 Survey Results, InfoMine USA, Inc., 2012 http://costs.infomine.com/laborcompensationreports/. The hourly wage rates were adjusted from 2012 to 2015 using a percent change of 5.8%, derived from the Bureau of Labor Statistics’ Employment Cost Index (ECI), CIU2010000405000I, for “private industry workers in Construction, extraction, farming, fishing, and forestry occupations,” http://www.bls.gov/ect/ and http://data.bls.gov/timeseries/CIU2010000405000I. ($103.26 = $97.60 x 1.058)
2 Hourly wage rates, including benefits, developed from tabulations in the U.S. Coal Mines Salaries, Wages, and Benefits – 2012 Survey Results, InfoMine USA, Inc., 2012 http://costs.infomine.com/laborcompensationreports/. The hourly wage rates were adjusted from 2012 to 2015 using a percent change of 5.8%, derived from the Bureau of Labor Statistics’ Employment Cost Index (ECI), CIU2010000405000I, for “private industry workers in Construction, extraction, farming, fishing, and forestry occupations,” http://www.bls.gov/ect/ and http://data.bls.gov/timeseries/CIU2010000405000I. ($76.42 = $72.23 x 1.058)
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| File Modified | 2016-10-31 |
| File Created | 2016-10-31 |